We are generally supportive of the development because it has a low level of parking provision. As Edinburgh continues to grow, we need to curtail and discourage more car travel from the city. Housing in dense brownfield sites like this this are the most sustainable kind of development, not only for the environment and transport purposes (beaches it is so easy to walk, cycle or go by bus) but also for the neighbourhood economy – local shops, community facilities etc get more customers This would support council policies which aim to promote car-free or car-lite developments: http://www.livingstreetsedinburgh.org.uk/common-issues/policies-of-city-of-edinburgh-council-promoting-car-freecar-light-developments/

However, thepublic realm in the immediate area is very deficient for people walking, despite this being a key North/South walking route. We would therefore like to see significant improvement in the nearby public realm funded from the developer. These improvements are (in approximate order):

Widening the pavement on Leamington Road, and to de-clutter it (almost all signage should come off it). This very important walking route between the Haymarket and Bruntsfield area is absolutely atrocious; the pavement should be at least 2 metres wide (preferably 2.5 metres) to conform to the Council’s own Street Design Guidance http://www.edinburgh.gov.uk/info/20089/roads_and_pavements/906/edinburgh_street_design . Unfortunately, it is hard to see how this can be achieved without removing the existing residents’ parking, which will clearly be unpopular with those that currently park there. Could alternative (off street) spaces be provided for them in the new development ?

Installing a ‘continuous pavement’ across Leamington Road at the junction with Gilmore Place. There is not even a ‘dropped kerb’ there at present and as a result Gilmore Place is a very difficult place for disabled people to move along. It would be criminal to miss this opportunity to address this (arguably even a breach of the Equality Act?)

Considering stopping up Leamington Road at the Gilmore Place junction, permitting access only by bicycle and on foot. (Vehicle access to be through the eastern end of Lower Gilmore Place)

Improving public realm on the north and east sides of Lower Gilmore Place. This might involve removing the canal-side wall to open up views and access to the canal towpath and decluttering the northern pavement of signage (which should have been done when the pavement was recently widened).

A continuous pavement should be installed across Lower Gilmore Place at the junction with Leamington Road, providing a flat surface for people walking along Leamington Road to and from the lift bridge.

Living Streets Edinburgh has submitted an official objection to the redevelopment of Boroughmuir High School due to the planned excessive car parking (planning ref 16/04581/FUL).

The full plans can be viewed here – https://goo.gl/IJsiFB

We object to the application on the grounds of excessive parking provision. The Transport Statement makes great play about how the proposed development supports the Council’s sustainable transport policies; however, we do not consider a development with 95 parking spaces to be consistent with the council’s transport and environmental objectives. The case made in the application comparing existing and projected traffic flows is spurious; obviously traffic generation will be totally different as it is no longer going to be a 1000+ pupil school. The application notes that it aims to achieve 68% of the permitted maximum; we propose on the contrary, that the development should be have the minimum permitted number of residents’ parking spaces (zero – i.e. a car-free development). Limited car parking for disabled people and visitors would be acceptable.

As the application notes, the site is extremely well-sited for travel by bus (eight frequent, regular services within three minutes’ walk), bicycle and on foot. The sustainability of the local Bruntsfield area will be enhanced by a car-free development which is actively aimed at people attracted to a car-free lifestyle. We strongly oppose the suggestion that there should be 16 new on-street parking spaces on Viewforth in addition, for the same reason. An option could be to site a car-club facility on or near the site.

The application incorrectly claims that the footways on Viewforth are at least 2m wide; in fact they are typically 1.8m on both sides (only wider at the Bruntsfield Place end and at one or two specific spots). The Council’s Street Design Guidance specifies the width for this kind of street as an “absolute minimum of 2m (only allowed in short sections), desirable minimum 2.5m or wider.” If the application were to be granted, the opportunity should therefore be taken to meet these standards in the vicinity of the development. Continuous pavements giving clear pedestrian priority (rather than dropped kerbs) should be provided on the Viewforth access points. The application also claims that there “no evidence of parked vehicles obstructing footway” (p8). This is patently not so and pavement parking is endemic at weekends and evenings owing to lack of TRO prohibitions. Again, if the application were to be granted, conditions should be attached to remedy this shortcoming.

Objection from Living Streets Edinburgh to Planning Application York Place / Elder st 15/04868/AMC

This objection is sent on behalf of Living Streets Edinburgh, a group that campaigns for improved conditions for pedestrians in the City. We also work to ensure that the City Council follows its own policies and guidance with regard to pedestrians.

We object to this application on a number of grounds:

It conflicts with the City Council’s Street Design Guidance, particularly with respect to footway widths.

It worsens conditions for disabled pedestrians (and by extension for all pedestrians) by introducing steps where none exist currently, and by failing to properly protect pedestrian space and crossing in the shared space area. Therefore by accepting this application as it is the Council would fail to comply with the law (Equality Act 2010).

It conflicts with the City Council’s Active Travel Action Plan by failing to provide comfortable, convenient and safe pedestrian routes.

The specifics of each of these points are as follows:

Pavement widths – Elder Street and York Pace are classed as a strategic retail / high streets in the Street Design Guidance and as such should desire to have a pavement width of 4 meters, with an absolute minimum of 2.5 meters. The application fails to meet this in a number of locations:

Elder Street, at the junction with York Place, north side, adjacent to loading bay / car park entrance;

Elder Street at the far right, top side;

The footway on the south/west side of Elder St also appears to have been split with part level, part on steps. If this is indeed the case then it also effectively narrows the footway below standard.

[Based on this application, we also have some concerns about the south side of York Place where a two way cycle lane appears to have been squeezed onto the pavement, however subsequent planning documents claim that the full pavement width has been retained, which we consider vital]

Equality Act and accessibility. Introduction of steps on north / east side of Elder Street – this footway currently provides step free access from York Place (east) to the St James Centre. There is no justification for placing new steps in this location. The step free route involves four separate road crossings rather than the current one, flagrantly disregarding the requirements of the Equality Act 2010 to improve (not worsen) conditions for disabled people. No contrasting coloured strip is shown to indicate the edge of the “footway” and the start of the “roadway” in the shared space area; again a vital feature from an accessibility point of view.

Comfortable, convenient and safe pedestrian routes. There should be a zebra crossing connecting Multrees Walk to the St James Centre. This street will still have vehicles driving up and down it and crossing pedestrians (especially older and disabled people) need priority crossing in what is essentially is a pedestrian area. The Street Design Guidance states that the Council will on such streets “Provide pedestrian crossing points every 50-100m, ideally associated with entrances to major buildings.”

The “footway” area in the shared space area should be protected with bollards to prevent the footway parking that takes there at present. Again, this also has Equality Act implications; footway parking is one of the most significant mobility issues for visually impaired pedestrians.

Within these plans there are two staggered junctions crossing York Place and Elder Street. Again both should be removed, as noted in the Street Design Guidance that states “Avoid staggered crossings”. It currently takes up to 3 minutes just to cross 22 meters of York Place (Youtube video showing crossing time). With the change in road layout with dedicated turning lanes it should be easy to remove the Elder street stagger as a minimum. It is also unclear where cyclists on York Place are supposed to cross this junction. Would they dismount and use the small pedestrian island?

At the main entrance to the St James Centre there appear to be 14 bike racks at 90 degrees to the footway. If these bike racks are used the footway will be blocked – particularly difficult for older and disabled pedestrians, and the many who have prams or are carrying shopping.

The swept path analysis only shows busses traveling to / from the west end of York Place. Nothing is shown from the east. Busses currently traveling from Elder Street heading east bound have to dangerously overhang the pavement on the north side of York place to clear the existing pedestrian island. No attempt has been made to remove this risk to pedestrians walking on the pavement.

Living Streets Edinburgh has a number of concerns about this application, which lead us to object to it. Our reading of the application leads us to believe that the developer has not fully considered the implications of their proposal for pedestrians, and where they have considered them, they have ignored key issues.

Our main objection relates to the issue of loading/unloading in the Cowgate and Victoria Street, but we highlight below further concerns about access to bus stops, and general pedestrian accessibility.

Loading & Unloading

The planning application proposes that coaches and goods vehicles will use the Cowgate for loading/unloading of goods and people. They’ve included a very narrow loading bay to facilitate this. However, the Cowgate is simply not wide enough at this point to accomodate vehicle loading.

The proposed loading bay will take away valuable pavement space. The pavements in this area are already very narrow – and are on a busy road. They’re currently 1.8m (at the back of this site ), and yet the developers want to NARROW them further, which seems likely to take them to the very minimum advised in the council’s own street guidance, given that the Cowgate is demarcated as a secondary retail/high st.

At present, deliveries to the site use the lane at the back of the Central Library up to the back of ‘Espionage’. They do not use the street as in the current proposal. The Cowgate is one of the only east / west roads left in the city center open to general traffic. Any blockage would have major knock on effects through the Cowgate and Grassmarket. Any vehicle loading or unloading would cause severe congestion within minutes. The proposed narrow loading bay would not facilitate 2 way traffic.

As can be seen elsewhere in the Cowgate, delivery vehicles frequently park on the pavement, forcing pavement users into the road. The damage caused by delivery vehicles can be seen throughout the Cowgate. It would be extremely deleterious to the pedestrian experience of Edinburgh, as well as costly to the council, if this practice were to be expanded any further.

For example, at the back of the recently opened Soco development an attempt was made by developers to build a loading bay on the pavement. This has not worked as vehicles often take up the entire loading bay AND pavement, again blocking the pavement for legitimate users.

Night-time closures

We also note that the site is within the night time road closures of Cowgate. There is no mention of this in the planning application. If a delivery vehicle or bus requires access 10pm till 6 am where do they park? If a vehicle does go through the no entry signs, parks on the Cowgate, how would it leave the site? Reverse out or drive through the closed road? Any of these options would again be disadvantageous to vulnerable road users such as pedestrians.

Narrow pavements and expanded footfall

Pavement narrows to just 85cm meters from the proposed development

This proposal will inevitably increase the number of pavement users on the Cowgate. No mention of this has been made in the application. To the east of this development the pavement narrows to just 85cm under George the 4th Bridge on both sides of the road. To the west pedestrians have to negotiate the very wide junction at the bottom of Victoria street.

With regards to Victoria Street the road narrows at the front of the development / behind the G&V Hotel. As can be seen in some of the photos in the application the pavements in this area have been badly damaged by delivery vehicles parking on them.

Any hotel guest trying to travel north will have to cross the 2 lanes of traffic at the top of Victoria Street. During the rush hour it can be difficult to cross this junction on foot. The increased number of vehicle movements on this street as a result of this development will only make the issue worse.

We are also concerned about the knock-on effects on Victoria St, which is likely to be used by coach or other delivery vehicles, especially those relying on SatNav. The street runs the risk of being overwhelmed if large vehicles attempt to negotiate this narrow street and become blocked.

Bus facilities- George IV bridge

The planning application makes note of the bus facilities nearby for use by its customers. It does not mention that you have to cross 4 lanes of heavy traffic on George IV bridge to get to them.

Our advice would be that if the development is approved, it should be on the condition that

An off-street loading / unloading / drop off point should be created off the Cowgate. The site is big enough for this. There’s an example of an off road delivery bay at the Smart City Hostel further along the Cowgate.

The pavements should be widened along this part of the site to at least the far side of the George the 4th Bridge.

A pelican crossing should be installed on George the 4th Bridge at the top of Victoria St to allow people to cross the road without having to walk up to the junction with the Royal Mile to be able to cross the road safely.

All pavements surrounding the site should be protected by bollards to prevent vehicles parking on the pavement. The upkeep and maintenance of these bollards and the paving stones should be met by the development.

During construction pedestrian traffic should be maintained on both sides of the road.

The bottom of Victoria Street at the junction with the Cowgate should be narrowed to allow pedestrians to cross the junction safely.

Along Victoria Street and the Cowgate more crossing points should be provided to allow pedestrians safer access to the development.